IRCCourt RulingsJul 14, 2005related by meaning
…axable years at issue;
(2) the Court's decision failed to reduce the amounts subject to
the section 274(n)(1) limitation pursuant to section 274(e)(3)
(petitioner's section 274(e)(3) argument); and (3) the Court's
decision did not reduce the respective deficiencies in
IRCCourt RulingsNov 21, 2007
…rwork
was received from petitioner by Norwest's office in Boulder,
Colorado, on or about October 7, 1998, and was forwarded to
Norwest's home office in Minneapolis, Minnesota . The paperwork
and the stock certificate were then sent to the transfer agent on
or about October 20, 1998, and the shares of stock were
registe…
IRCCourt RulingsMar 6, 2001★ strong match
v. Commissioner
, T.C. Memo. 1998-140; Reiher v.
Commissioner
, T.C. Memo. 1998-75; Easter v. Commissioner
, T.C.
Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd.
without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette
v. Commissioner
, T.C. Memo. 1997-301; Hayes v. Commissioner
, T.C.
Memo. 1…
IRCCourt RulingsDec 28, 2004
… of time to file. Petitioner also did not
file timely income tax returns for years before and after 1998. Petitioner filed his 1994 return on August 8, 1996, his 1995
return on February 13, 1998, his 1996 return on November 23,
1998, his 1997 return on February 4, 2001, and his 1999 return on
June 6, 2002.
On January 1…
IRCCourt RulingsFeb 9, 2023★ strong match
…nation of the 1982 trademark licensing agreement and the 1983 licensing agreement; execution of the 1998 trademark
licenses; stipulations related to Brazilian law
On August 18, 1998, 3M Company and 3M Brazil entered into an
agreemen t terminating the 1982 trademark licensing agreement,
effective January 1, 1998.
On Aug…
IRCCourt RulingsNov 10, 2004★ strong match
…ent’s litigating
position that the distribution occurred in 2000. See Garcia v.
Commissioner
, T.C. Memo. 1998-203 (reaching this conclusion
regarding another question and answer contained in the same
proposed regulation), affd. without published opinion 190 F.3d
538 (5th Cir. 1999). Additionally, the substantially lev…
IRCCourt RulingsJun 18, 1997related by meaning
… years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
T.C. Memo. 1997-277
UNITED STATES TAX COURT
MARGARET M. MERKER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26855-95. Filed June 18, 1997.
Margaret M. Merker, pro se.
Marjory A. Gilbert
, for respon…
IRCCourt RulingsOct 24, 2007
…eview
because she trusted that Mr. Barrera “would do the best” for her
and her family.
- 13 -
7
The 1998 collection notice was not in respondent’s
administrative record and was not presented as evidence at trial.
Respondent introduced Form 4340, Certificate of Assessments,
Payments, and Other Specified Matters, dated M…
IRCCourt RulingsAug 22, 2002
am at the University of
Phoenix commenced on September 30, 1998. The “Student Schedule
Listing” provided by petitioner shows only two courses in 1998, “Role of the Nurse Practitioner,” a three-credit course held at 6
p.m. each Wednesday between September 30, 1998 and November 4,
1998, and “Advanced Nursing Theory,” als…
IRCCourt RulingsJun 3, 1998★ strong match
…stituted a
modification of the terms of the notes. We have previously
noted that a technical advice memorandum is merely a ruling
given to a specific taxpayer based upon the taxpayer's
specific facts and is not a ruling of general application.
See Golden Belt Tel. Association, Inc. v. Commissioner
, 108
T.C. 498, 506 (…
Rev. Proc. 2021-30 — Rev. Proc. 2021-30 adds two new benefit overpayment correction methods that encourage employers to avoid seeking recoupment of benefit overpayments made to par… IRCRevenue ProceduresModified Aug 2, 2021
…Period)
+12% If the $5,000 corrective contribution had been contributed for Employee X on March 31, 1998, (1) Earnings for 1998 would have been increased by the amount of the Earnings on the additional $5,000 contribution from March 31, 1998 through December 31, 1998 and would have been allocated as 1998 Earnings in pr…
Rev. Proc. 2018-52 — The revenue procedure modifies and supersedes Rev. Proc. 2016–51, 2016–42 I.R.B. 465, which sets forth the Employee Plans Compliance Resolution System (“EPCRS”… IRCRevenue ProceduresOct 15, 2018
…Period)
+12% If the $5,000 corrective contribution had been contributed for Employee X on March 31, 1998, (1) Earnings for 1998 would have been increased by the amount of the Earnings on the additional $5,000 contribution from March 31, 1998 through December 31, 1998 and would have been allocated as 1998 Earnings in pr…
IRCCourt RulingsJun 18, 1999related by meaning
the facts have been stipulated, and they are so
found. Petitioner resided in Omaha, Nebraska, at the time that
his petition was filed with the Court. For the year in issue, petitioner and his wife filed a joint
Federal income tax return reporting wage income, which was earned
by petitioner's wife, in the amount of $4,…
Rev. Proc. 2016-51 — This revenue procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements o… IRCRevenue ProceduresOct 17, 2016
…Period) +12% If the $5,000 corrective contribution had been contributed for Employee X on March 31, 1998, (1) Earnings for 1998 would have been increased by the amount of the Earnings on the additional $5,000 contribution from March 31, 1998 through December 31, 1998 and would have been allocated as 1998 Earnings in pr…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
IRCCourt RulingsSep 3, 1998related by meaning
…his Court under substantially identical circumstances. See
Steel Balls, Inc. v. Commissioner
, T.C. Memo. 1995-266, affd.
without published opinion 89 F.3d 841 (8th Cir. 1996).
6
We
rejected the same argument presented herein and concluded that
respondent's position was clearly supported by the statute and
regulations.…
Rev. Proc. 2008-50 — This procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements of sectio… IRCRevenue ProceduresSep 2, 2008
…Period) +12% If the $5,000 corrective contribution had been contributed for Employee X on March 31, 1998, (1) earnings for 1998 would have been increased by the amount of the earnings on the additional $5,000 contribution from March 31, 1998 through December 31, 1998 and would have been allocated as 1998 earnings in pr…
Rev. Proc. 2006-27 — Administrative programs; correction programs. This procedure updates and expands upon the Service’s comprehensive Employee Plans Compliance Resolution System (… IRCRevenue ProceduresSuperseded May 30, 2006
…Period) +12% If the $5,000 corrective contribution had been contributed for Employee X on March 31, 1998, (1) earnings for 1998 would have been increased by the amount of the earnings on the additional $5,000 contribution from March 31, 1998 through December 31, 1998, and would have been allocated as 1998 earnings in p…
IRCCourt RulingsAug 25, 1997related by meaning
…reply brief includes 4-½ pages of objections to respondent's
proposed findings of fact. Id
.
I. The Memorandum Opinion
In T.C. Memo. 1995-492, filed October 11, 1995, the Court
decided the present case. In our memorandum opinion, we rejected
petitioners' argument that petitioner's Transfer Refund had not
been received …
IRCCourt RulingsOct 3, 1989related by meaning
…nal activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms that the recreational activitie…